Topic 4: Collaborate with states to develop shared access to all public water systems (PWS) monitoring data.

2010 July 29

We want to collaborate with state and local partners to improve information exchange. Since the rules for public water systems monitoring data reporting were written, advances in information technology increase possibilities for EPA and states to exchange critical information. EPA currently receives only violation data. Creating an exchange for all public water systems data collected will let us do more without adding to the information collection burden. We want to share powerful information technology tools to better target program oversight, compliance assistance, and enforcement to areas of highest risk. We want to make our work and the information exchange interactive and transparent. New communications tools can enable states, industry, and most importantly consumers to learn more about their drinking water. We envision a system where people will have better access to timely information about the water that is piped into their homes.

What do you think are the opportunities and barriers to public water systems submitting data electronically to states?

Do you have ideas about how EPA should share occurrence data with the public to communicate the quality of drinking water transparently?

What concerns do you have about EPA receiving all the data systems report to the states?

How can systems and EPA ensure data quality?

Editor's Note: The opinions expressed here are those of the author. They do not reflect EPA policy, endorsement, or action, and EPA does not verify the accuracy or science of the contents of the blog.

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I see no issue with sharing information across state lines only if it eliminates the need to register separatly with each state.

As a supplier of sanitization products to the industry, it is very cumbersome to make a change to directions on a registered product or introduce a better product to the market when we have to work with the EPA, state regulators and California. It’s time consuming, costly and often times, the information coming back from the various groups contradicts the others!

I applaud the idea of making it easier to get access to PWS information. Although we can get annual water quality reports for larger water systems since they are required to post them on websites, it would be helpful to be able to get them for all systems. Since state or county Departments of Health get those, could they post the results on their websites? Or an EPA website would be great.

In addition, I would like to be able to see the water quality monitoring results for community schools. It appears that unless they are boarding schools, they do not need to make results available.

While not currently a part of the annual water quality report, I think it would also be useful to see the annual water usage, number of users, and average water use per user. Water quantity will be as important as water quality soon and we need to start getting people aware of it. We may need to understand our commercial and agricultural water use as well, and comparisons across areas may be beneficial.

Opportunity of submitting data – takes design, but obvious benefits.
Barriers – many of the water systems are small. Our community water system (90 homes) is run by volunteers (of course with the oversight of an operator in charge and licensed operators in the community.) We need to be able to submit information without having to buy a proprietary product or create a unique software application. We are computer literate but certainly don’t have staff that could do this.

Share data transparently – I think making the details available is the first step. Local news media should be educated about the data and pointed to the results, and that’s one way to get it out there. The public should also be able to find information on the potential contaminants very easily.

I have no concerns about EPA receiving state data. I think that some of the major issues can only be addressed at a federal level and the EPA needs to have data to know what the issues could be, whether this is information on fracking, the need to limit aquifer withdrawals, or specific contaminants.

Data quality – ensure that it is sent by authorized states, authorized lab, or PWS. Ask the PWS to validate their data before it is published.

Potable Water Forum-Applies to parts 2,3 and 4
Ensuring water quality data:

EPA has historically researched and Regulated the chemical aspects of water Emergent Contaminants of Concern (ECC) but not the biological water Contaminants of Concern. Now, the most potentially dangerous and, therefore, urgent areas of concern are the multi-antibiotic resistant organisms. This must be priority No. 1. re: preservation of Public Health.

The international medical, water and biological literature includes pertinent research by various authors including EPA scientist, Meckes (1982) documenting that:
-potable water at the end of wastewater treatment processes and later at the points of use (POU) cultures out multi-antibiotic organisms that are potentially dangerous to Public Health. The use of single indicator testing is antiquated because it does not accurately reflect the universe of pathogens, especially those existing in water requiring high level disinfection.
-contamination of potable water is, in large part, due to insufficient high level disinfection by wastewater treatment facilities of a.) recycled water (which leaves multi-antibiotic resistant organisms and their genetic fragments in agricultural ground) and b.) biosolids with the same contamination both washed off by stormwater from agricultural and/or pasture lands into river tributaries and aqueducts carrying wastewater treatment plant processed water to disinfection facilities which produce potable water.
-there is no Regulated testing or culturing of chlorinated water at the points of use even though the literature documents that chlorine can:
-increase resistance and virulence of some organisms and
-shock ( kill or arrest) multi-antibiotic resistant organisms which often revive after a period of time.
-organisms need not be killed by chlorine because it is their genetic fragments that transfer the resistance to our normal intestinal tract organisms (see Griffith, 1928)
-it only takes a tiny genetic fragment to transfer the resistance and/or virulence to the normal organisms in our intestinal tracts. Once transferred, the medical use of antibiotics may not be able to kill or arrest organisms already in our systems that have initiated serious infectious disease both in immune compromised people or even people with normal functioning immune systems. This genetic fragment phenomenon is not characterized as a dose-response issue.
– filtering the disinfected water with pores small enough to remove the tiny genetic fragments exactly at the points of use is essential.
– culturing the multi-antibiotic resistant organisms must take place at the points of use after the above filtering and before the distribution to points of use.
-it is essential that Federal and State Regulations for both wastewater treatment plants and disinfection facilities (just prior to points of use) be upgraded to deal effectively with the above sanitization of potable water.
-Federal and State Regulations must convert to new cutting edge technologies that upgrade the processes of wastewater treatment plants by incinerating and therebye removing the contaminated biosolids suspended in wastewater prior to entering wastewater facilities. The incineration produces a methane type gas that can be used to power other equipment or be sold. Strategic metals can be recovered from the ash. Such new technology will usually create a profitable bottom line. The footprint of the plant will be substantially smaller.
-the above type filters must be manufactured and utilized prior to the distribution of potable water.
– the understanding of the culturing for multi-antibiotic organisms and the need both for a.)the above types of cutting edge wastewater treatment plants and b.) the creation and utilization for the above filters will definitely help the public and private sectors to invest in advanced drinking water technologies (for example,MicroMediaFiltration: 949-380-9800; info@mmfwater.com).
– CDC and Public Health must be part of the initiation of upgraded Regulatory requirements.

What data to access, and even what data to collect, will depend upon the perceptions of the harm of withdrawing water and impact of pollution from the discharge of water. The International Organization for Standardization (ISO) is writing a water footprint standard that will probably be referenced to quantify the harm of withdrawing water and discharging polluted water. Everyone who has concerns over this international evaluation of the impact of water withdrawal and pollutants discharged to water should voice their opinion. To participate in the writing of ISO 14046 Water footprint – Requirements and Guidelines, please contact the US administrator of the activity: standards@asq.org.

1. Make sure the provider of the water has a means to validate the data before it is published.
2. If erroneous data is published, have a way to remove the data and replace with accurate data.
3. Could this forum replace the current annual CCR requirement?

Don’t see much of any response here from actual water system operators or managers. With almost any of the public systems whether is be large metro, small village, or rural systems the means to track, validate, and then submit data for a system is continually becoming more burdensome, time consuming, and costly!
The thought of again having to be mandated to gather and supply drinking water system info to be openly shared on public access channels becomes worrisome and disturbing. When the concept of sharing and making more municipal utility information publicly accessible started a few years back, it became evident that it might not be such a good idea to continually assume making more information available is always a benefit for all.
The placement of public water system information of where wells and treatment facilities were located, (with actual street addresses), just did not seem a “good idea” and when that concept was questioned; the upper government agency doing so conceded that it wasn’t really in the best interest of those local systems to have such info shared with everyone and anyone that could choose to do a system harm.
Putting too much information at the fingertips of anyone that can use the data to elevate the agenda of even more unfunded mandates, “is Not” in the best interests of most public water systems. Most local governing agencies know their responsibility to oversee, operate, and distribute safe & healthy drinking water to their consumers. There surely is no system that willingly intentionally plans on an incident that brings about “Boil Water Notices” or any such actions.
Things do happen, things do change, but any and all operators I know, & talk with continually have their hands “full” with meeting government requirements of the SDWA and the other regs which continually, & are currently mandated to increase due to the way the rules were originally written.
There must be some common sense “restraint” to “jump the gun” on concerns when there are isolated incidents of water system neglect or ignorance. More training, mentoring, and sharing of operator knowledge at the system operation level will be the “Key to Solving & Resolving” both current and coming issues with drinking water. The Federal oversight agency “Will Not” be the ones to make it work.
They can be a guiding force, a spearhead to make a change in direction, plus an aiding force in the funding for such changes. But with such challenges as deterioration of infrastructure, along with cutbacks in funding at local levels, & some areas with out of control spending in prior years leading to record indebtedness; there needs to be more focus from the federal level to recognize and respond to the state agencies which work directly with the “Local” down-home systems & “do know” those systems.
No blanket fixes for the country work well for all. The system has taken on the mentality of the federal bureaucracy thinking “they” can fix it all. That can & will only be done at a local level, when you give the local agency some guidance and then the flexibility to choose what’s best for their system and their citizens.
Too bad the EPA system has gotten to big to realize the regional meetings for input and discussion on most critical subjects needs to be on a much more “Localized region” where many local systems can take the time and effort to put their thoughts and emotions into the eyes and ears of the federal regulators.
Write your Congress person & Senators. Give the control and choices back to the states and the local governments. That’s the way the founding fathers planned the government system. They wanted the use of checks & balances to make sure one area of government couldn’t overpower another and that states could retain their sovereignty along with being a teamwork player in the USA republic.
Technical progress has made regulators able to sense, find, and validate the presence of particles in our drinking water systems, which couldn’t have been detected years ago. When there is no shown evidence that many of these natural elements were at current levels maybe even hundreds of years ago, we can’t expect to change the course of what Nature does.
We can work to “manage” the critical concerns for a local system by using the most effective and efficient technology available, but again that choice should be made locally. The overabundance of any amount of data can make for much confusion, just look to the amount of info on the Gulf oil spill. What should we do, what should we have done? How about global warming or the lack thereof? What should we do, what do water systems need to do, or not do?
Many questions, but no government agency has the answers, they can give guidance, but those “Local” agencies will, and still do have the ability to make things happen. Give us some breathing room and watch what “We” the system operators can make happen. We’ll bring clean, clear, safe, healthy water to your tap and you can save the bottle for something else, not just filling up our landfills creating another government agency & environmental challenge.
These are just some thoughts and ideas coming from a concerned, conscientious, and committed public water system operator in today’s regulated world.

Opposition to this idea stems around feasibility and the ability of local governments to handle their own matters without EPA intervention.

For the issue surrounding local governments, I do not see this as a question of whether local water systems managers can handle their own duties. This should be about information collection, rather than process intervention. The reality of water is that it moves. Whether it is via groundwater or surface water, contaminants do not stay in one location. If there is a problem upstream, it is beneficial for the downstream residents to have access to this information so that they may face any challenges sooner rather than later. Learning about problems after they already exist can be more costly, and even more dangerous.

There is always a problem with mandatory disclosure and the overabundance of information. There are limits to the idea that “sunlight is the best disinfectant.” With information located in several dispersed sources, people become overwhelmed and disinterested. However, if the EPA was able to create a database, and hopefully publish the information online in an intuitive, user-friendly manner, this would be a step toward overcoming the barrier of dispersed, irrelevant information. My suggestion for the website is that users may be informed of common patters of migration for water that arrives in their area along with city water quality information so that there is some warning as to whether contaminated water may possibly reach them.

I think an informational approach like the one proposed has many benefits especially if combined with the other factors suggested by the EPA, like encouraging technology development. By making information of water quality available to the public, it would allow the public to react and make sure the people they are voting into office are concerned with encouraging the technology development needed to address the issues. It might be costly to assign a person or group of persons within the agency to oversee and manage the extra data that would be coming in since the data wouldn’t relate only to violations any more, but if the Agency requires that the data be authorized for accuracy before being sent into the EPA, off-setting the cost onto the state water source, then maybe all they’d need is a statistical program that can crunch the numbers and supply the information over the EPA website.

Although I don’t have a suggestion about how the EPA should create an exchange for all public water systems data collected, I hope that the EPA continues to work towards this goal. While the vast majority of our environmental progress to date has come from laws and government programs, the role of informed citizen groups should not be understated. For instance, citizen groups watch for NPDES permit notices, check facilities compliance history on ICIS and submit letters to state or federal authorities notifying them of compliance problems that should be addressed before a permit is renewed. The violation data is helpful, but providing a fuller picture will enable these organizations to better serve the public.